Privacy Policy - Eurocommercial Properties N.V.

PRIVACY STATEMENT

EUROCOMMERCIAL PROPERTIES N.V.

 

This is the privacy statement of Eurocommercial Properties N.V. and, unless stated otherwise, its subsidiaries, together hereinafter referred to as ‘Eurocommercial’ and ‘we’. This privacy statement aims to inform you about the way we – and our affiliates – process your personal data. Please read this statement carefully. The most recent version of our privacy statement will always be available online on our website.

 

For the processing of personal data as set out herein, Eurocommercial is the data controller, unless stated otherwise.

Why do we process personal data and what are our grounds for processing?

Eurocommercial, as a controller, processes personal data of the following categories of data subjects:

1.    Employees and applicants;

2.    Professional contacts, such as:

a.    recipients of press releases and retail news, and

b.    investors; and

3.    Contacts of suppliers.

 

We process personal data of our employees and applicants in order to execute the employment contract and/or to establish one. For more information on the way we process personal data of employees, we kindly refer you to the privacy statement for employees.

 

Press releases and retail news

We process names and contact details of parties who are interested in receiving our press releases and retail news, such as people who explicitly signed up to receive the press releases and/or retail news. We also process business contact details of journalists who – based on their area of expertise – have an interest in receiving press releases. If you signed up to receive our press releases or retail news, it means you used the opt-in option on our website and gave us your consent for processing your data in order to send you our press releases. If you are a journalist and you have not explicitly opted-in to receive our press releases, the ground for processing your personal data is our legitimate interest in informing you of news worth spreading. As a listed company, it is our duty to inform the public of news regarding our company. Naturally, we do not process more personal data than is necessary to make sure you receive our press releases and we only process your business contact details.

 

Investors

We also process financial information regarding our investors, such as investment details. We process these personal data because on the basis of a legal obligation and to execute the investment contract we have with you.

 

Suppliers

We store contact details of our suppliers. In most cases those contact details concern natural persons acting on behalf of our supplier. We need to process these personal data to execute the contract we have with our supplier or to establish a contract with the supplier. We only process business information and which is limited to the information that is necessary for the aforementioned purposes.

Do we transfer your personal data?

Eurocommercial does not transfer your personal data to countries outside of the European Union. We do not share your personal data with third parties, unless we are obliged to by law or it is necessary to execute a contract we have. We may share your data between Eurocommercial group entities and certain regulated professionals such as lawyers, notaries or auditors.

 

Eurocommercial engages processors, which are third parties who process (y)our personal data on our behalf and upon our written instructions. We transfer your data to those processors. To protect that data, we have data processor’s agreements in place with all our data processors.

The categories of processors are:

-      intermediaries for job applicants;

-      financial institutions;

-      payroll administrator;

-      IT service providers; and

-      marketing companies.

 

Eurocommercial itself acts as a processor for the processing of personal data by its subsidiaries in Italy, Sweden, Belgium and France, as most personal data is stored at Eurocommercial Properties N.V. in Amsterdam.

How long do we store your personal data?

We do not store your data longer than is necessary for the purposes we obtained that data, unless there is a legal obligation to retain the data. In general, we will retain your data for a period of 2 years after our relationship has ended (i.e. you unsubscribed from our news letters or you are no longer our supplier). Data that is relevant for tax purposes will be stored for a period of 5 or 7 years, depending on the retention periods prescribed by law.

What are your rights?

As a data subject, you have several rights under the privacy laws.

 

Right to withdraw consent

If you have given us consent to process your data, you have the right to withdraw your consent at any time. Withdrawing your consent, however, does not mean that the processing of your personal data before the withdrawal was unlawful.

 

Right of access

You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, you have the access to said personal data.

 

Right to rectification

You have the right to rectify inaccurate personal data that concerns you. You also have the right to have incomplete data completed, taking into account the purposes of the processing.

 

Right to restriction of processing

You have the right to obtain restriction of processing where one of the following applies:

-      The accuracy of the personal data is contested by you, in which case we will pause the processing of your data until we have verified the accuracy of your personal data;

-      The processing is unlawful and you do not want us to erase your personal data;

-      We do no longer need your personal data for the purposes of the processing, but you require us to store the data for purposes of establishing, exercising or defending a legal claim;

-      You have objected to the processing pursuant to your right to object (as set out in this paragraph) and you are pending the verification whether the legitimate grounds of Eurocommercial override those of yours.

 

Right to object

If the processing of your data is based on a legitimate interest of Eurocommercial, you have the right to object said processing on grounds relating to your particular situation. We will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or unless we have the need for the data for the establishment, exercise or defense of legal claims.

 

In case of an execution of the right to object, we will weigh your interests against our own interests or those of relevant third parties.

 

Right to be forgotten

In some cases, you will have the right to be forgotten. This means that we will have to erase all of your personal data. You have this right in the following cases:

-      The personal data are no longer necessary in relation to the purposes for which they were collected;

-      If the processing was based on consent and we have no other grounds for processing, and you withdraw your consent;

-      You’ve successfully used your right to object;

-      The personal data have been unlawfully processed;

-      The retention periods have lapsed;

-      You are younger than 16 years old and your data is being processed in relation to the offer of information society services.

 

You do not have the right to erasure if we have a legal obligation to process your data or if the data is necessary for us to establish, defend or exercise a legal claim.

 

Right to data portability

Insofar that Eurocommercial processes your data (by automated means) based on your consent or to execute a contract we have with you, you have the right to receive the data that you have provided to us in a structured, commonly used and machine-readable format. You may also request us to transfer the data to another controller directly.

 

Automated decision-making

We will not make decisions by automated means and/or profiling, concerning you or affecting you.

How can you contact us?

Within Eurocommercial, Vincent Meijer is the contact person for all privacy related questions or issues. You may contact him by calling +31 (0)20 530 60 30 or sending an e-mail to Vincent.Meijer@ecpnv.com. If you have any complaints regarding the way we process your data, please let us know. Please note that you may file a complaint with the Data Protection Authority (Autoriteit Persoonsgegevens) at all times, but we hope to be able to work towards a solution together.

 

Eurocommercial entities

·        Eurocommercial Properties N.V., Herengracht 469, 1017 BS Amsterdam,
+31 (0)20 530 60 30.

·        Eurocommercial Properties Sweden AB, Kungsgatan 48, 111 35 Stockholm,
+46 (0)8 678 53 60.

·        Eurocommercial Properties Belgium N.V., Rue Saint-Lambert 200, 1200 Woluwe-Saint-Lambert, +32 (0)2 374 339 1.

·        Eurocommercial Properties France S.A.S., 107 rue Saint Lazare, 75009 Paris,  
+33 (0)1 48 78 06 66.

·        Eurocommercial Properties Italia S.r.l., Via della Moscova 3, 20121 Milan,  
+39 02 760 759 1.